`Filed: January 29, 2016
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`
`INNOPHARMA LICENSING, INC., INNOPHARMA LICENSING LLC,
`INNOPHARMA INC., INNOPHARMA LLC,
`MYLAN PHARMACEUTICALS INC., and MYLAN INC.,
`Petitioner,
`
`v .
`
`SENJU PHARMACEUTICAL CO., LTD., BAUSCH & LOMB, INC., and
`BAUSCH & LOMB PHARMA HOLDINGS CORP.
`Patent Owner.
`__________________
`
`Case IPR2015-00902 (Patent 8,669,290 B2)
` Case IPR2015-00903 (Patent 8,129,431 B2)1
`__________________
`
`PETITIONER’S NOTICE OF CROSS-EXAMINATION OF
` DR. ROBERT O. WILLIAMS, Ph.D.
`
`
`
`
`
`
`1 A word-for-word identical paper has been filed in each proceeding
`
`identified in the heading. IPR2015-01871 has been joined with IPR2015-00903
`
`and includes Petitioners Lupin Ltd. and Lupin Pharmaceuticals Inc. in addition to
`
`the parties identified above.
`
`
`
`
`
`
`
`
`
`Case IPR2015-00902 (Patent 8,669,290 B2)
`Case IPR2015-00903 (Patent 8,129,431 B2)
`
`Pursuant to 37 C.F.R. § 42.53, Petitioners INNOPHARMA LICENSING,
`
`INC.,
`
`INNOPHARMA
`
`LICENSING
`
`LLC,
`
`INNOPHARMA
`
`INC.,
`
`INNOPHARMA LLC, MYLAN PHARMACEUTICALS INC., and MYLAN
`
`INC., (“Petitioner” or “InnoPharma”), by and through its attorneys, will conduct a
`
`cross-examination by deposition of Dr. Robert O. Williams regarding his
`
`declarations submitted in IPR2015-00902 and IPR2015-00903. Dr. Williams’
`
`cross-examination will take place, as agreed by counsel for the parties, on February
`
`11, 2016, commencing at 9:00 a.m. (local time), at a reasonably agreeable location
`
`in Austin, Texas. Counsel for Patent Owner has represented that Dr. Williams is
`
`willing to appear at the time and location indicated above.
`
`The cross-examination will take place before a Notary Public or other officer
`
`authorized by law to administer oaths. It will be recorded using at least audiotape
`
`and/or stenographic means. InnoPharma also intends to video record the cross-
`
`examination of Dr. Williams. The arrangements for the reporter and videographer
`
`will be made by counsel for Petitioners.
`
`
`
`
`
`/Jitendra Malik/
`
`Jitendra Malik (Reg. No. 55823)
`Alston & Bird LLP
`4721 Emperor Boulevard, Suite 400
`Durham, North Carolina 27703
`Telephone: 919-862-2200
`
`1
`
`Date: January 29, 2016
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Case IPR2015-00902 (Patent 8,669,290 B2)
`Case IPR2015-00903 (Patent 8,129,431 B2)
`
`Fax: 919-862-2260
`Jitty.Malik@alston.com
`
`Lead Counsel for Petitioner
`InnoPharma Licensing Inc., InnoPharma
`Licensing LLC, InnoPharma Inc.,
`InnoPharma LLC, Mylan
`Pharmaceuticals Inc., and Mylan Inc.
`
`2
`
`
`
`
`
`CERTIFICATION OF SERVICE
`
`The undersigned certifies that on the 29th day of January, 2016, a copy of
`
`the foregoing Petitioner’s Notice of Cross-Examination of Dr. Robert O. Williams,
`
`Ph.D was served via email directed to counsel of record for the Patent Owner and
`
`counsel of record for Petitioners Lupin at the following:
`
`Patent Owner
`
`Bryan C. Diner
`bryan.diner@finnegan.com
`
`Justin J. Hasford
`justin.hasford@finnegan.com
`
`Joshua L. Goldberg
`Joshua.goldberg@finnegan.com
`
`Petitioners Lupin Ltd. and Lupin Pharmaceuticals Inc.
`
`Deborah H. Yellin
`DYellin@Crowell.com
`
`Jonathan Lindsay
`JLindsay@Crowell.com
`
`
`Respectfully submitted,
`
`Alston & Bird LLP
`
`By: /Jitendra Malik/
`
`Jitendra Malik, Ph.D.
`Reg. No. 55823
`Alston & Bird LLP
`4721 Emperor Blvd., Suite 400
`Durham, NC 27703-8580
`
`
`
`
`
`
`
`
`
`Case IPR2015-00902 (Patent 8,669,290 B2)
`Case IPR2015-00903 (Patent 8,129,431 B2)
`
`jitty.malik@alston.com
`
`Bryan Skelton, Ph.D.
`Reg. No. 50893
`Alston & Bird LLP
`4721 Emperor Blvd., Suite 400
`Durham, NC 27703-8580
`bryan.skelton@alston.com
`
`Lance Soderstrom
`Reg. No. 65405
`Alston & Bird LLP
`90 Park Avenue
`15th Floor
`New York, NY 10016-1387
`lance.soderstrom@alston.com
`
`Hidetada James Abe
`Reg. No. 61,182
`Alston & Bird LLP
`333 South Hope Street
`16th Floor
`Los Angeles, CA 90071
`james.abe@alston.com
`
`Attorneys for Petitioners InnoPharma
`Licensing, Inc., InnoPharma Licensing LLC,
`InnoPharma Inc., InnoPharma LLC, Mylan
`Pharmaceuticals Inc., and Mylan Inc.
`
`2
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